Facility Contact with Commercial Finishing Corp. - Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
October 5, 2021
Subject
Data collection
Stakeholder
Timothy Hughes 
(317) 267-0337
EPA in attendance
-
ERG in attendance
Bryan Lange
Mission:
The Clean Air Act requires the EPA to periodically review and revise its federal rules. We are asking for your help with this requirement for the NSPS Subpart TTT (Surface Coating of Plastic Parts for Business Machines). Commercial Finishing Corp was identified in an EPA database as subject to Subpart TTT. We collected your air permit and have confirmed this. 
We have prepared a short telephone survey for facilities that are subject to this rule. We hope to learn more about the impact of the 1988 rule, ways it might be improved for future facilities, and to look for innovation in the control of air pollution (e.g., new add-on control technologies, new work practices or operational procedure).  After the call we can share with you a copy of the minutes and discuss any necessary changes.
 Describe your business and surface coating process and approximately what fraction of your operation is used to coat plastic parts for business machines:
Commercial Finishing Corp. has the ability to coat plastic under their permit, but the facility does not currently. Further, Commercial Finishing has not coated plastics in approximately 5-years. 
Our largest customer is Caterpillar. We coat metal with powder for exhaust parts. The powder is cured in a 400F oven for 30-minutes. Powder coating could not be used on plastics because the curing temperature would melt the plastic part. 
 Do you have other industry contacts that are knowledgeable about the rule and might have useful input in our review?
Timothy Hughes suggested Keco also in Indianapolis as a facility that might perform surface coating of plastic parts for business machines. 
ERG pulled the Keco permit. It did not include subpart TTT and permit documents indicated the coat small metal automotive parts.

